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Tax

As business becomes more global, taxation is becoming an increasingly complex issue in all countries. Taxation is now a core consideration in the decision-making process, and companies must have a real national and international taxation strategy covering both direct and indirect taxes. These same trends are affecting people as well as companies

Our Practice Areas

General taxation of private and state-owned enterprises including handling tax disputes

Patrimonial taxation

Taxation of national and international mergers & acquisitions and restructuring

Taxation in the financial sector

Property taxation

Transfer pricing

VAT

Local taxes

Non-salary benefits (stock options, incentive schemes, etc.)

Our Approach

Co-operation between lawyers specialising in each area of taxation and in other areas of law.

Collective expertise acquired from more than 80 years of experience and practice in the most complex of taxation issues.

Risk management: with our skills and expertise, we provide clients with effective and reliable advice on their strategic and tactical choices.

Supportive relationship with our clients in their dealings with the tax authorities and in pre-litigation and litigation procedures.

Ability to handle a client’s overall tax strategy, both national and international, through our international network of offices and partner firms in CMS

Our Clients

We advise medium-sized companies and major groups in all business sectors, as well as public organisations, local authorities and individuals.

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The EU Eco­nom­ic and Fin­an­cial Af­fairs Coun­cil has ad­op­ted a Dir­ect­ive to cre­ate a new sys­tem to re­solve double tax­a­tion dis­putes between EU Mem­ber States. This meas­ure will af­ford tax­pay­ers a trans­par­ent pro­cess with clear dead­lines ap­plic­able to tax au­thor­it­ies.

Ap­pro­pri­ate Use of Coun­try-by-Coun­try Re­ports
The OECD has now pub­lished Guid­ance (avail­able here) on the ap­pro­pri­ate use of Coun­try-by-Coun­try Re­ports (‘Cb­CRs’) by na­tion­al tax au­thor­it­ies. This is in re­sponse to some val­id MNE con­cerns that tax au­thor­it­ies.

In the 2015 Sum­mer Budget, pro­pos­als were an­nounced to change the UK tax re­gime for non-dom­i­ciles. These pro­pos­als were the sub­ject of a con­sulta­tion pa­per which was pub­lished on 19 Au­gust 2016. The new re­gime will take ef­fect as planned from 6 April 2017.

On 1 Feb­ru­ary, Fin­ance Min­is­ter Ar­un Jait­ley presen­ted In­dia’s an­nu­al Uni­on Budget for 2017-2018 (the “Budget”) for the fisc­al year be­gin­ning 1 April 2017. The cent­ral aim in this year’s Budget ap­pears to fo­cus on the most vul­ner­able with in­creased spend­ing.

The OECD has now pub­lished the mul­ti­lat­er­al in­stru­ment (“MLI”) that will im­ple­ment cer­tain of the treaty-re­lated pro­pos­als from its pro­ject on tack­ling base erosion and profit shift­ing (“BEPS”).

Au­tumn State­ment: Re­forms to the tax­a­tion of non-dom­i­ciled in­di­vidu­als

The UK’s Chan­cel­lor of Ex­chequer de­livered his an­nu­al Au­tumn State­ment today. As pre­vi­ously an­nounced at the 2015 Sum­mer Budget and fol­low­ing the HM Treas­ury con­sulta­tion pub­lished on 19 Au­gust 2016, the gov­ern­ment has con­firmed that from April 2017: .

In the 2015 Sum­mer Budget, pro­pos­als were an­nounced to change the UK tax re­gime for non-dom­i­ciles. These pro­pos­als were the sub­ject of a con­sulta­tion pa­per Re­forms to the Tax­a­tion of Non-dom­i­ciles: fur­ther con­sulta­tion which was pub­lished on 19 Au­gust 2016.

EU Mem­ber States re­cently reached an agree­ment on the EU Anti Tax Avoid­ance Dir­ect­ive 2016/0011 (the “Dir­ect­ive”). The Dir­ect­ive is aimed at tax plan­ning prac­tices cur­rently widely used by mul­tina­tion­al com­pan­ies and builds on the OECD's Base Erosion and Profit.